Welcome to the law school’s master calendar! Use the “Event Category” filter below to find events by intended audience. (For example, if you are an alum, click on the Event Category button below and select “Alumni” from the drop-down menu; the calendar will then display events open to alumni). Please note that this is a public-facing calendar that contains all events happening on campus, any details that you wish to remain private to the UC Law SF community should not be included in your event submission. Changes to your event submissions may be directed to: website@uclawsf.edu.
- This event has passed.
Complexities, Discontinuities, and Unintended Consequences of U.S. International Tax Rules: Options for Change
September 12 @ 9:30 am - 4:00 pm
The 2017 Tax Cuts and Jobs Act (TCJA) introduced the most significant changes to U.S. international tax rules in almost a century. These changes were built on an already-complex tax system, and after 2025, some of the most important rate provisions are set to increase. This legislation has had global impacts as well, as seen with the OECD’s global minimum tax.
The time is ripe to consider whether current international tax law is achieving its desired policy goals, and how the law could and should be modified to better respond to global developments.
Join scholars and international tax practitioners as they discuss a series of papers considering options for reforming U.S. international tax rules.
An east coast version of this conference was organized by the American Enterprise Institute and the University of Florida and was held June 17-18, 2024 in Washington, D.C. More information about that conference can be found here. This west coast version of the conference will focus on the international tax provisions most relevant to technology- and intangibles-based enterprises.
We are extremely grateful to Baker McKenzie, Fenwick, PwC, Skadden, and Miller & Chevalier co-sponsoring this event.
Program Schedule
9:30 am – 10:00 am Registration (lobby of 198 McAllister Street)
10:00 am – 10:15 am Welcome, Opening Comments, and Conference Overview
Mindy Herzfeld, Professor of Tax Practice, University of Florida
Heather Field, Stephen A. Lind Professor of Law, UC Law San Francisco
10:15 am – 11:15 am Session 1: Taxing of CFC Earnings – GILTI and Subpart F
The panelists will explore design issues of Subpart F income and GILTI, their differences, and opportunities for harmonization post TCJA.
Presenter: Kara Mungovan (Davis Polk)
Commentators: Gretchen Sierra (Deloitte), Brian Jenn (McDermott)
11:15 am – 12:30 pm Session 2: Foreign Tax Credit
The panelists will discuss recommendations for improving the Foreign Tax Credit system including recommended approaches to limitations, basketing, expense allocation, among others.
Presenter: Moshe Spinowitz (Skadden)
Commentators: Julia Ushakova-Stein (Fenwick), Rachel Kleinberg (Sidley)
12:30 pm – 1:15 pm Lunch
1:15 pm – 2:00 pm Session 3: Sourcing Rules
This panel will discuss some of the pitfalls and difficulties associated with the domestic source of income rules, potential for reexamination of the sourcing rules, and considerations for whether potential reforms could simplify the current system.
Presenter: Nita Asher (PwC)
Commentator: Gary Sprague (Baker McKenzie), Chad Hungerford (Deloitte)
2:00 pm – 2:15 pm Break
2:15 pm – 3:00 pm Session 4: FDII Benefit
The panelists will discuss policy goals for enacting FDII compared to other regimes, whether these goals were met, and areas for potential improvements.
Presenter: Pat Brown (PwC)
Commentator: Kyle Pomerleau (AEI), Becky Lester (Stanford)
3:00 pm – 3:45 pm Session 5: Transfer Pricing
This session will focus on whether the regulatory arm’s length standard should be incorporated into the statute, whether the special statutory rules applicable to intangible property should be restated or reconsidered in light of developments, whether ancillary transfer pricing rules should be better coordinated with section 482, and whether other changes should be considered in light of developments in U.S. law or international guidelines.
Presenter: Rocco Femia (Miller)
Commentator: Nate Carden (Skadden), Rafi Mottahedeh (Shartsis Friese)
3:45 pm – 4:00 pm Closing Remarks
Mindy Herzfeld, Professor of Tax Practice, University of Florida
Heather Field, Stephen A. Lind Professor of Law, UC Law San Francisco
Logistical information:
This event will be held in the auditorium in the 198 Academe. This building is located at 198 McAllister Street; San Francisco, CA 94102
The BART stop closest to the law school is Civic Center.
If you drive, parking is available at the UC Law SF Parking Garage located at 376 Larkin St, San Francisco, CA 94102. https://sites.uclawsf.edu/garage/parking-rates/
The UC Law SF Events Calendar offers a comprehensive list of campus events, including co-curricular programming, faculty lectures, colloquia, wellness activities, alumni events, larger departmental meetings, and events sponsored by College departments, faculty, law journals, and registered student orgs. This functions as the College’s master calendar, which includes all events taking place on campus on any particular day. Students, faculty, or staff: Please visit Sharknet for information regarding guidelines and procedures for events. Alumni: please filter events by the category “alumni.”